BIR Ruling No. 001-83

January 3, 1983 BIR RULING NO. 001-83 This refers to your letters dated January 20 and April 22, 1982 requesting a ruling as to whether pawnshops like the Durian City Pawnshop, Inc. and the Martinez Pawnshop, Inc. may be considered as lending investors. In reply, please be informed that lending investors and pawnshops are subject to separate fixed taxes, in accordance with Sections 192(3)(dd) and (ff) of the Tax Code. Moreover, under Section 209 of the Tax Code, only the lending investor is subject to the percentage tax at the rate of 5% of his gross income. This shows that our internal revenue law does not consider a pawnshop a lending investor as defined in Section 187(u) of the Tax Code. Hence, pawnshops are subject only to the fixed tax of one thousand pesos (P1,000.00) under Section 192(3)(ff) of the Tax Code. cdta Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue